ML20059L084
| ML20059L084 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 01/31/1994 |
| From: | Thayer J YANKEE ATOMIC ELECTRIC CO. |
| To: | Fairtile M NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| BYR-94-003, BYR-94-3, NUDOCS 9402030133 | |
| Download: ML20059L084 (4) | |
Text
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YANKEE A TOMIC ELECTRIC COMPANY "C"yl. "jll*;"l"
( Ya-.kLL, 580 Main Street. Bolton, Massachusetts 01740-1398 N.
uxte January 31,1994 BYR 94-003 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Attention:
Mr. Morton Fairtile Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support
References:
(a)
License No. DPR-3 (Docket No. 59-29)
(b) letter, T. Murley, U. S. Nuclear Regulatory Commission (NRC) to A. Kadak, Yankee Atomic Electric Company (YAEC), dated March 29,1993 (c)
Staff Requirements Memorandum, S. Chilk, NRC to W.
Parler and J. Taylor, NRC, dated January 14,1993 (d) letter, H. Tracy, YAEC to M. Fairtile, NRC, dated December 30,1993 (c) 12tter, J. Thayer, YAEC to M. Fairtile, NRC, dated April 23, 1993
Dear Mr. Fairtile:
Subject:
COMPONENT REMOVAL ACTWITIES la Reference (b), the U. S. Nuclear Regulatory Commission (NRC) provided Yankee Atomic Electric Company (YAEC) with the Commission's guidance criteria for use in determining which activities could be conducted prior to approval of a decommissioning i
plan (Reference (c)). The first two Commission criteria address licensing and technical guidance which the licensee should use to ensure continued public health and safety.
The third of the Commission's guidance-criteria addresses use of decommissioning trust funds for legitimate decommissioning activities. In Reference (d), YAEC informed the NRC of YAEC's plans to conduct additional decommissioning activities at the Yankee Nucicar Power Station (YNPS) and requested permission to use decommissioning funds for those activities, i
This letter is informational in nature and describes how YAEC intends to address the Commission's first two guidance criteria. YAEC wishes to emphasize that the information that follows has been provided previously to NRC in licensing correspondence and at meetings. The information also has been reviewed by the NRC.
9402030133 94o331 PDR ADOCK 05000029
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U. S. Nuclear Regulatory Commission Page 2 of this letter lists the numerous inspection reports and licensin" documents i
which contain more detailed information.
Discussion The first of the Commission's guidance criteria states that after permanent shutdown of a facility,10 CFR 50.59 should be applied on the basis of an assumption that the facility will not resume operation, provided that a possession-only license has been issued for such facility. YAEC will continue to apply 10 CFR 50.59 on the basis that YNPS is permanently shutdown and defueled and maintains a possession-only license.
The second of the Commission's guidance criteria addresses the potential impacts of decommissioning activities. The following addresses each subpart of the second criterion.
(a)
The activity does not foreclose the release of the site for_possible unrestricted use.
The additional activities planned by YAEC are described in Reference (d). As presented in Reference (d), the activities are legitimate decommissioning activities because they involve processes which are needed to assess or to remove components that are radiologically contaminated. The activities allow for the reduction in residual radioactivity levels, thereby contributing to the eventual release of the YNPS site for unrestricted use and termination of the YNPS 10 CFR Part 50 license. The activities, therefore, would not foreclose release of the site for unrestricted use.
(b)
The activity does not significantly increase decommissioning costs.
As presented in Reference (d), implementation of the additional decommissioning activities is $1 million to $2 million less than the cost of the same activities in the current YNPS decommissioning cost estimate. The activitics, therefore, would not increase the cost of decommissioning.
(c)
The activity does not cause any significant environmental impact not oreviously reviewed.
In Reference (c), YAEC explains in detail how this guidance criterion will be addressed for activities conducted prior to approval of a decommissioning plan.
In summary, YAEC will ensure that decommissioning activities are bounded by NUREG-0586, " Final Generic Environmental Impact Statement on Decommissioning "
U. S. Nuclear Regulatory Commission Page 3 (d)
The activity does not violate the terms of the licensee's existing license or 10 CFR 50.59 as applied to the existing license.
As stated earlier in this letter, YAEC will continue to apply the requirements of 10 CFR 50.59 on the basis that YNPS is permanently shutdown and defueled and maintains a possession-only license. YAEC will not conduct any activity which
'?olates the conditions of its possession-on:v license or the requirements of 10
( J4 50.59.
YAEC will review the above criteria as part of a proceduralized design control process that will be performed to support the removal activities.
Summary YAEC is providing the above information to describe the process that will be used to assure that activities initiated before approval of the decommissioning plan are reviewed and determined to be consistent with NRC guidance. YAEC will continue to keep the NRC apprised of its schedule for conduct of activities so that NRC may audit the documents / evaluations that support conduct of the subject activities.
Sincerely, YANKEE ATOMIC ELECTRIC COMPANY
//w I /
j
[rk. Thayer Vice President and Manager of Operations c:
R. Dudley NRC, NRR NRC Region 1 Administrator
6 ATTACIIMENT 1 The following licensing and inspection correspondence documents YAEC's approach to conduct of activities prior to approval of a decommissioning plan and NRC's review of YAEC's activities.
Letter, J. Thayer, YAEC to M. Fairtile, NRC, dated January 12, 1993 re: response e
to NRC request for additional information - component removal activities Letter, II. Tracy, YAEC to M. Fairtile, NRC, dated March 5,1993 re: use of e
decommissioning trust funds Letter, II. Tracy, YAEC to M. Fairtile, NRC, dated March 25,1993 re: use of e
decommissioning trust funds Ixtter, II. Tracy, YAEC to M. Fairtile, NRC, dated April 8,1993 re: use of e
decommissioning trust funds Letter, M. Fairtile, NRC to H. Tracy, YAEC, dated April 16,1993, re: completion e
of NRC's review of YAEC's use of decommissioning trust funds Letter, J. Thayer, YAEC to M. Fairtile, NRC, dated April 23,1993 re:
)
e Commission guidance criteria for pre-decommissioning plan activities Meeting, NRC and YAEC, June 9,1993, re: implementation of Commission's e
guidance criteria for pre-decommissioning plan activities e
Letter, M. Fairtile, NRC to J. Grant, YAEC, dated June 16,1993 re: Commission guidance criteria for pre-decommissioning plan activities i
Letter, J. Thayer, YAEC to M. Fairtile, NRC, dated June 17,1993 re:
e Commission guidance criteria for pre-decommissioning plan activities i
e Letter, R. Mellor YAEC to M. Fairtile, NRC, dated June 24,1993 re:
Commission guidance criteria for pre-decommissioning plan activities I etter, S. Weiss, NRC to J. Thayer, NRC, dated July 15, 1993 re: completion of e
NRC's review of YAEC's implementation of Commission guidance criteria on pre-decommissioning plan activities NRC Inspection Report 50-29/93-04, dated July 16,1993 re: radiological controls NRC Inspection Report 50-29/93-05, dated August 19,1993 re: implementation of e
Commission's guidance criteria for pre-decommissioning plan activities NRC Inspection Report 50-29/93-07, dated December 28,1993 re: radiological e
controls